Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency of $26,943.59 in petitioners' 1978 Federal income tax.
Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the period at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issue for decision is whether to treat as interest under section 163 the amount designated...
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